The basic issue here is whether VoIP companies will be allowed to
obtain numbers directly from NANPA. Right now, when a VoIP company
wants a block of numbers, they have to go to a CLEC that has numbers
assigned to them, and use numbers out of the CLEC's number pool. The
problem with this is that the CLEC then owns the numbers rather than
the VoIP company. Consider the case of where a CLEC is giving poor
service or goes out of business; calls to customers may not complete
properly and it may not be the VoIP company's fault, but rather the
fault of the CLEC that owns the number.

So, allowing this change would let the VoIP company to own their own
numbers, and therefore they would have both more flexibility and more
responsibility. When a CLEC that the VoIP company partners with isn't
completing calls properly, the VoIP company could move the termination
point for the numbers to another CLEC. I think allowing this change
would allow VoIP companies to provide better service to customers, and
by the way it would also probably remove the current impediments for
customers wanting to take their phone number from one VoIP provider to
another (or to a landline or cellular company, for that matter -- in
other words, local number portability for VoIP numbers would probably
be a reality).

Maybe I'm missing something but I don't see any real downside to this.
Those that just don't like VoIP will probably find some reason to
oppose it but I think that if VoIP companies had control of their own
number space, rather than using numbers out of the various CLEC's
pool, it would make thing far easier for everyone. Note this has
nothing to do with whether they would still use the CLEC's for actual
call completion, it only addresses who owns the block of numbers out
of which customer numbers are assigned.

RNK, Inc. d/b/a RNK Telecom (RNK), Nuvio Corporation (Nuvio), Unipoint
Enhanced Services d/b/a PointOne (PointOne), Dialpad Communications,
Inc. (Dialpad), Vonage Holdings Corporation (Vonage), and VoEX,
Inc.(VoEX) have filed petitions with the Commission for a limited
waiver of section 52.15(g)(2)(i) of the Commission's rules. The
petitions request a limited waiver of the Commission's numbering
rules to allow RNK, Nuvio, PointOne, Dialpad, Vonage, and VoEX to
obtain numbering resources from the North American Numbering Plan
Administrator (NANPA) and/or the Pooling Administrator (PA). RNK,
Nuvio, Point One, Dialpad, Vonage, and VoEX seek the same relief that
the Commission granted in an Order allowing SBCIS to obtain numbering
resources directly from the NANPA and/or the PA until the Commission
adopts final numbering rules for IP-enabled services.

We invite comment on the Petitions for Limited Waiver. Pursuant to
applicable procedures set forth in sections 1.415 and 1.419 of the
Commission's rules, interested parties may file comments on or
before April 11, 2005; and reply comments on or before April 26,
2005. Comments may be filed using the Commission's Electronic
Comment Filing System (ECFS) or by filing paper copies. See Electronic
filing of Documents in Rulemaking Proceedings, 63 Fed. Reg. 24121
(1998).

[End of excerpt]

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